How UK creators can use the CAP Code and ASA rulings to check a media kit

What to take away

How the ASA and CAP Code system governs media kit claims

In the UK, advertising is regulated independently by the Advertising Standards Authority. It administers the CAP Code, the rulebook that media kit claims must comply with. The UK advertising codes sit alongside the BCAP Code for broadcast ads, but for a creator pitching brands it is the CAP Code that matters.

A media kit is not exempt because it is a PDF rather than a paid ad. The Code's scope lists advertisements in mailings, e-mails and other electronic or printed material, and it defines a consumer as anyone likely to see a marketing communication, whether in the course of business or not, so a brand manager reading a kit counts. The same scope section excludes private correspondence. Whether a one-page deck sent to a single brand is caught therefore depends on the facts, and the safe working assumption for a kit that promotes a service, a rate card or a collaboration is that it is covered.

The system is co-regulatory. The ASA investigates complaints and publishes rulings. It does not fine creators directly. Instead it names them, asks for changes and escalates when they refuse.

Section 3 of the CAP Code does most of the work here. It covers misleading advertising, and within it rule 3.7 covers substantiation, which means holding evidence before you publish, not after a brand asks. Section 2, on recognising marketing communications, matters for any sample posts the kit shows.

A media kit claim can be misleading by omission as well as by statement. Leaving out that a follower count includes bought or inactive accounts can breach the Code even if the number itself is accurate.

For a fuller walkthrough of how these duties land on a single document, see our guide to advertising rules for creator decks.

The CAP Code clauses that apply to audience and performance figures

Clause 3.1 says marketing communications must not materially mislead or be likely to do so. A rounded-up follower figure, a screenshot from a spike week or a vague "millions reached" line all sit under this clause.

Clause 3.3 says marketing communications must not omit material information, including by giving it in a way that is unclear or untimely. A follower total that hides bought or inactive accounts, or an engagement figure without its period, is an omission problem.

Clause 3.7 requires that claims be substantiated: before distributing a marketing communication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective. If you state an engagement rate, you need the underlying data and a clear method. A platform dashboard export is evidence; a memory of a good month is not.

Comparisons have their own principle. The ASA treats unqualified superlative claims as comparative claims against all competing products, and superiority claims must be supported by evidence unless they are obvious puffery. "Best engagement in my niche" is such a claim. Without a defined niche, a measured period and a source, it breaches the Code.

Clause 3.11 says marketing communications must not mislead consumers by exaggerating the capability or performance of a product. For creators, this catches promises such as assured sales or assured reach, which no creator can substantiate.

Four more rules matter for media kits. Clause 3.2 allows obvious exaggerations ("puffery") only where they do not materially mislead. Clause 3.9 says a communication must not mislead by omitting significant limitations and qualifications, which covers an audience figure that is true only for one platform or one month. Clause 3.17 says price statements must not mislead by omission, undue emphasis or distortion, relevant if your rate card shows a discount. Clause 3.47 requires documentary evidence that a testimonial or endorsement is genuine, and contact details for the person who gave it, relevant if you quote a brand client.

The practical test is simple. Write the claim as a sentence a stranger could check. If you cannot point to a file, a dashboard or a signed contract that proves it, rewrite it.

Specific figures need specific sources. A follower count comes from the platform. An engagement rate comes from a defined window. A conversion figure comes from the brand's own reporting, and you should say so.

Reading ASA rulings as a test for your own media kit claims

The ASA publishes a searchable rulings database at Rulings - ASA | CAP. It is free, indexed by advertiser and by subject, and it is the closest thing to a case law library for media kit wording.

Search for the categories your kit uses: influencer, social media, testimonials, comparative claims, pricing. Read the reasoning, not just the outcome. The ASA explains which clause failed and why.

A worked test case: the Dress Like A Mum ruling

The ASA ruling on Zoe de Pass, trading as Dress Like A Mum, is a useful test for the sample posts in a kit. It concerned an Instagram post about a shoe range she had designed with Air & Grace, and it was published as upheld on 20 November 2019. The creator argued that the post was a design collaboration rather than an ad. The ASA found that because the post promoted the collaboration and was directly connected to the supply of goods, it was a marketing communication within its remit. It then said consumers needed to know that the post was an ad before clicking to view the full caption.

Run the same two questions over your kit. First, would a post you show as a sample be a marketing communication on those facts, even if you call it a collaboration? Second, is the label visible before anyone clicks? A sample whose label sits below the fold in the caption fails the second test, and a kit that offers brands that kind of post invites the same complaint.

A typical pattern in influencer rulings is an unqualified claim about results. The advertiser could not show a basis for the figure, so the ASA upheld the complaint on substantiation.

Another pattern is a claim that was true for a subset of followers but presented as true for all. That is a misleading-by-omission finding, and it maps directly onto media kit audience summaries.

Treat each ruling as a template. Ask whether your own wording would survive the same reasoning. If a ruling turned on a missing time period, add the period. If it turned on a missing method, add the method.

Keep a written file per claim: the figure, the source, the date pulled and the person who checked it. This doubles as your claim register when the kit is next updated.

Rulings also show how quickly a small wording change resolves a problem. Many upheld cases could have been avoided by adding "in the period measured" or "according to platform analytics".

Where CMA disclosure guidance and the CAP Code overlap

Two regulators touch the same document. The ASA enforces the CAP Code on advertising content. The Competition and Markets Authority enforces consumer protection law on misleading commercial practices.

The CMA publishes Social media endorsements: guidance for content creators - GOV.UK. It explains when a creator must make a commercial relationship clear to the audience.

A media kit sits upstream of that disclosure. If the kit promises brands a certain style of promotion, the wording should not imply that disclosure can be softened or buried. Promising undisclosed promotion is itself a misleading claim.

In practice, keep the two duties separate in your head. The CAP Code governs what you say about your numbers. CMA guidance governs how you label paid relationships in the content that follows.

The overlap appears in sample content. If your kit includes example posts, those examples should show correct labelling. A sample that hides the ad label is a poor template and a compliance risk.

This is where a disclosure policy earns its place in the kit. State how you label paid work, where the label appears and who checks it before posting.

Brands increasingly ask for this. A kit that answers the disclosure question before it is asked reads as more professional, not more cautious.

A plain checklist for checking each figure before publication

Work through this list figure by figure. One claim, one pass. Do not batch it at the end.

Then take each kind of figure in turn:

A worked example shows how this lands. A creator writes "120k followers, 9% engagement, best in the fitness niche".

The follower figure is fine once the platform and pull date are stated. The engagement rate needs a defined window and a stated method, or it fails substantiation.

The comparative line fails outright. There is no defined niche, no measured peer group and no source. Rewrite it as a factual statement about your own audience, or drop it.

A revised version might read: "120,000 Instagram followers as at 1 September 2026. Average engagement rate 9% across posts published between June and August 2026, measured from Instagram Insights."

That version is longer but defensible. It also gives a brand something it can actually plan around. For a fuller review of permissions and personal data in the same document, see our notes on UK rules on claims.

Using Copy Advice and the AdviceOnline Library before release

The ASA runs a free, confidential pre-publication service called Copy Advice - ASA | CAP. You send the wording, not the whole deck, and you get a view on whether it is likely to breach the Code.

Use it for the riskiest lines, not the whole kit. Comparative claims, result claims and anything with a number attached are the priority.

Copy Advice is not a pre-clearance assurance. It gives an informed opinion, and a later complaint is still judged on its own facts. Even so, it is the cheapest way to find a problem before a brand does.

Alongside it, the AdviceOnline Library holds topic notes and case examples. Search for the subject of your claim, such as testimonials, pricing or social media metrics.

The library is useful for drafting, not just checking. Reading the notes first often changes the wording you write, which saves a revision cycle later.

Build this into your publishing routine. Before a kit goes out, run the three riskiest lines through Copy Advice. Keep the response with your evidence file.

Sanctions, non-compliant advertiser lists and Trading Standards referrals

The ASA prefers to resolve cases by getting an ad changed or withdrawn. Most media kit issues end there, with a quiet amendment.

When an advertiser will not comply, the ASA publishes the case and applies ASA sanctions. These include naming the advertiser, asking search engines and social platforms to remove paid ads, and targeting the advertiser's own marketing.

For repeat offenders, the ASA can refer the matter to Trading Standards. That moves the issue from reputational pressure into a legal channel, which is a materially worse position for a creator business.

Persistent breaches can also lead to a listing on the non-compliant online advertisers list. The list names advertisers whose ads remain non-compliant, and it is public.

A creator's reputational risk sits here. Brands check. An ASA ruling against your name in a search result is a harder sell than a corrected figure would have been.

Sanctions are rare for a first, minor breach, which is why early correction matters. The system rewards fixing the claim quickly and documenting what changed.

Common questions